PRIVACY POLICY

1. Introduction

CINE TECH LIMITED respects your privacy and protects your personal data according to international data protection standards and payment network rules.

2. Information We Collect

We may collect:

Name
Email address
Phone number
Billing information
IP address
Website usage data

3. How We Use Data

Your data is used to:

Provide services
Process payments
Offer customer support
Improve website performance
Prevent fraud

4. Payment Security

We do not store card numbers. Payments are processed through secure, PCI-DSS compliant providers.

5. Data Sharing

We do not sell personal data. Information may be shared only with:

Payment processors
Legal authorities if required
Service partners needed to deliver services

6. Data Protection

We use:

SSL encryption
Secure servers
Access controls

7. Your Rights

You may request:

Data access
Data correction
Data deletion

Email: [Insert Contact Email]

8. Cookies

We use cookies for analytics and performance improvement.

Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it.
The Gravatar service privacy policy is available here: https://universaldistiny.com/privacy
After approval of your comment, your profile picture is visible to the public in the context of your comment. Media If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment.
These cookies will last for one year. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies.
This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices.
Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser.

This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day. Embedded content from other websites Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Who we share your data with If you request a password reset, your IP address will be included in the reset email. How long we retain your data Suggested text:

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue. For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information. What rights you have over your data If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Where your data is sent Visitor comments may be checked through an automated spam detection service.

CINE TECH LIMITED This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the general principles and procedures for processing personal data of Website Users and measures to ensure their security by CINE TECH LIMITED. TERMS AND DEFINITIONS

The Parties shall use the following terms in the following meaning: Data – other data about the User (not included in the concept of personal data). Legislation – the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and other applicable laws and regulations of the

Hong Kong Special Administrative Region. Data User – CINE TECH LIMITED (Business Registration Number: 79657779), which controls the collection, holding, processing or use of personal data. Personal Data – any data relating directly or indirectly to an individual from which it is practicable for the identity of that individual to be directly or indirectly ascertained, and that is in a form in which access to or processing of the data is practicable. User – a person who has access to the Website via the Internet and uses the Website of the online store.

Provision of Personal Data – actions aimed at disclosing Personal Data to a specific person or a certain group of persons. Website – a website located on the Internet at the address crmall.uz. Data Subject – the User (individual) to whom the Personal Data relates.
Transport Companies – third parties that provide courier services. PCPD – The Office of the Privacy Commissioner for Personal Data of Hong Kong. Other terms used in the Policy are interpreted in accordance with the Legislation of Hong Kong.

1. GENERAL PROVISIONS 1.1. This Policy regarding the processing of personal data has been developed in accordance with the provisions of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and determines the procedure for working with Personal Data of Users and requirements for ensuring their security. 1.2. Measures to ensure the security of personal data are an integral part of the Data User’s activities.

1.3. CINE TECH LIMITED is committed to complying with the six Data Protection Principles under the PDPO. 2. DATA PROTECTION PRINCIPLES
2.1. The processing of Personal Data by the Data User is carried out in accordance with the following principles based on the PDPO:

2.1.1. Principle 1 – Purpose and Manner of Collection Personal data shall be collected for a lawful purpose directly related to a function or activity of the Data User, and the collection shall be necessary for or directly related to that purpose. The collection shall be done by lawful and fair means. 2.1.2. Principle
2 – Accuracy and Retention The Data User shall take all practicable steps to ensure that personal data is accurate having regard to the purpose for which the data is or is to be used, and shall not keep personal data longer than is necessary for the fulfilment of the purpose for which the data is or is to be used.

2.1.3. Principle 3 – Use of Personal Data Personal data shall be used only for the purpose for which the data was collected or for a directly related purpose, unless the Data Subject has given voluntary and express consent for the use of the data for another purpose.

2.1.4. Principle 4 – Security of Personal Data The Data User shall take all practicable steps to ensure that personal data is protected against unauthorised or accidental access, processing, erasure, loss or use.

2.1.5. Principle 5 – Openness The Data User shall take all practicable steps to ensure that a person can ascertain the Data User’s policies and practices in relation to personal data, the kind of personal data held by the Data User, and the main purposes for which personal data is used.

2.1.6. Principle 6 – Access and Correction A Data Subject shall have the right to request access to and correction of his/her personal data held by the Data User.

3. CONDITIONS FOR PERSONAL DATA PROCESSING
3.1. Processing of Personal Data by the Data User is permitted in the following cases:

3.1.1. When the User has given voluntary and express consent to the processing of his/her Personal Data. Consent is given by accepting the Terms and Conditions posted on the Website or by placing an Order in the ways specified on the Website.

3.1.2. When the User transfers the Personal Data of the Data Subject when placing an order on the Website. The User guarantees that he/she has previously obtained consent from the Data Subject to transfer data to the Data User.

3.1.3. When Personal Data is required to be disclosed in accordance with the Legislation or by court order.

3.2. The Data User does not disclose or transfer Personal Data to third parties without the consent of the User, unless otherwise provided by the Legislation.

3.3. The Data User processes sensitive personal data (such as data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, health, sexual life, criminal records) only with the express consent of the Data Subject or as permitted by law.
3.4. The Data User may transfer Personal Data outside Hong Kong in accordance with Section 33 of the PDPO, ensuring that the transferred data will be protected to a standard comparable to that provided under the PDPO.

4. COLLECTION AND PROCESSING OF PERSONAL DATA 4.1. The Data User collects and stores only those Personal Data that are necessary to provide services to the User for the sale of goods through the Website. Personal Data may be collected both through the Website and at the Data User’s office.

4.2. The Data User processes Personal Data for the following purposes:

4.2.1. Conducting business activities in accordance with the laws of Hong Kong;

4.2.2. Fulfilling the Data User’s obligations to the User for the sale of goods, including payment processing and delivery of goods;

4.2.3. Communicating with Users when necessary, including sending notifications, information and requests related to the provision of services, as well as processing applications, requests and inquiries of Users;

4.2.4. Improving the quality of services provided by the Data User;

4.2.5. Promoting services through direct marketing (subject to obtaining separate consent where required);

4.2.6. Conducting statistical and other research based on anonymized personal data.

4.3. For the purposes specified in clause

4.2, the Data User processes the following personal data: Surname, first name and middle name; Email address; Telephone number; Delivery address; IP address of the User; User’s browser type and device information.

4.4. Personal Data and other User Data shall be kept confidential, except when such data is made publicly available by the User.
4.5. The Data User has the right to maintain an archived copy of Personal Data, including after the deletion of the User’s account, for the period required by law or for legitimate business purposes.
4.6. The Data User has the right to transfer Personal Data without the User’s consent to the following entities:
4.6.1. Government authorities, law enforcement agencies, and regulatory bodies upon their lawful request or as required by law;

4.6.2. The Data User’s service providers and business partners for the purpose of fulfilling contractual obligations to the User;
4.6.3. In other cases directly provided for by the laws of Hong Kong.
4.7. The Data User has the right to transfer Personal Data to third parties not specified in clause

4.6 in the following cases:
4.7.1. The User has given express consent to such transfer;
4.7.2. The transfer is necessary for the User’s use of the Website or the sale of goods to the User (including for delivery purposes);

4.7.3. The transfer occurs as part of a business sale or merger (in whole or in part), with all obligations under this Policy transferred to the acquiring entity.

4.8. The Data User employs both automated and manual processing of Personal Data.

4.9. Access to Information Systems containing Personal Data is protected by password systems and encryption. Passwords are assigned by authorized employees and communicated individually to employees who have authorized access to Personal Data. 4.10. The Data User transfers processed information to transport (courier) companies based on the User’s consent for delivery purposes.
4.11. The Data User shall not be liable for improper processing of Personal Data carried out by third-party Transport Companies beyond its reasonable control.
4.12. Upon receipt of a written request from the Data Subject to cease processing personal data, the Data User shall, within 40 (forty) calendar days from the date of receipt, cease such processing unless required by law to continue.

5. CORRECTION AND DELETION OF PERSONAL DATA 5.1. The User may at any time request correction (update, supplement) of Personal Data by sending a written request to the Data User.
5.2. The Data User shall respond to data access and correction requests within 40 calendar days as required under the PDPO.

5.3. The User has the right to request deletion of Personal Data at any time, subject to legal retention requirements.
5.4. The Data User may charge a reasonable fee for processing data access requests in accordance with the

PDPO. 6. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA
6.1. The Data User shall implement all practicable security measures to protect Personal Data against unauthorized or accidental access, processing, erasure, loss or use, including: Physical security measures for premises and equipment; Technical security measures including encryption, firewalls, and access controls; Administrative measures including staff training and confidentiality agreements; Regular security audits and updates.

6.2. Confidentiality is not required in relation to:
6.2.1. Personal data after anonymization;

6.2.2. Personal data made publicly available by the User or with the User’s consent;

6.2.3. Personal data subject to mandatory disclosure under Hong Kong law;

6.2.4. Information provided to transport companies and service providers acting under agreement with the Data User to fulfill obligations to the User.

7. USER’S CONSENT TO PROCESSING OF PERSONAL DATA 7.1. The User decides to provide Personal Data to the Data User and consents to their processing freely, voluntarily and in his/her own interest. Consent to the processing of Personal Data must be voluntary, express and informed, and is provided by the User at the time of Registration on the Website or placing an order.
7.2. For direct marketing purposes, the Data User shall obtain separate opt-in consent from the User before using Personal Data for such purposes.
7.3. The User may withdraw consent at any time by contacting the Data User through the contact information provided in this Policy.
8. RIGHTS OF DATA SUBJECTS 8.1. The Data Subject has the right to:
8.1.1. Request access to his/her Personal Data held by the Data User;

8.1.2. Request correction of inaccurate or incomplete Personal Data;

8.1.3. Be informed of the kinds of Personal Data held, purposes of use, and classes of recipients;
8.1.4. Withdraw consent for processing or direct marketing use;

8.1.5. Request cessation of use of Personal Data for direct marketing purposes.
8.2. To exercise these rights, the Data Subject should submit a written request to the Data User using the contact information provided in Section 11.
8.3. If the User believes that the Data User processes Personal Data in violation of the PDPO or infringes upon rights and freedoms, the User has the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) or seek remedies in court.

8.4. The User has the right to seek compensation for damages resulting from a contravention of the PDPO by the Data User. 9. PERSONAL DATA OF THIRD PARTIES PROVIDED BY USERS
9.1. When using the Website, the User may enter data of third parties (e.g., recipients of goods).
9.2. The User undertakes to obtain prior consent from such third parties before providing their Personal Data through the Website. The User is solely responsible for obtaining such consent.
9.3. The Data User undertakes to take necessary measures to ensure the security of Personal Data of third parties entered by the User. 10. RETENTION OF PERSONAL DATA

10.1. Personal Data shall be retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

10.2. The Data User maintains a data retention schedule that specifies retention periods for different categories of Personal Data based on: Legal and regulatory requirements; Business and operational needs; The nature of contractual relationships with Users. 10.3. Upon expiry of the retention period, Personal Data shall be securely destroyed or anonymized.
11. CROSS-BORDER DATA TRANSFER 11.1. The Data User may transfer Personal Data outside Hong Kong for business purposes such as data storage, processing, or service provision.

11.2. When transferring Personal Data outside Hong Kong, the Data User shall take all reasonable steps to ensure that the data recipient provides a level of protection comparable to that under the PDPO, which may include: Entering into data transfer agreements with appropriate safeguards; Transferring data only to jurisdictions with adequate data protection laws; Obtaining express consent from the Data Subject where required.
12. COOKIES AND TRACKING TECHNOLOGIES

12.1. The Website may use cookies and similar tracking technologies to enhance user experience, analyze website traffic, and personalize content.
12.2. Users can manage cookie preferences through their browser settings. However, disabling cookies may affect the functionality of certain Website features.
13. MISCELLANEOUS

13.1. This Policy and relations between the User and the Data User arising from this Policy shall be governed by the laws of the Hong Kong Special Administrative Region.
13.2. All disputes shall be resolved in accordance with Hong Kong law and under the jurisdiction of Hong Kong courts.
13.3. Before initiating legal proceedings, the User should comply with the mandatory complaint procedure by sending a written complaint to the Data User. The Data User shall respond within 40 (forty) calendar days. 13.4. If any provision of this Policy is found to be invalid or unenforceable, such invalidity shall not affect the validity or enforceability of the remaining provisions. 13.5. The Data User reserves the right to amend this Policy at any time (in whole or in part) unilaterally. All changes become effective immediately upon posting on the Website.
13.6. The User is responsible for regularly reviewing this Policy to stay informed of any changes. 14. CONTACT INFORMATION Company Name: CINE TECH LIMITED Business Registration Number: 79657779 Address: Units A-C, 25th Floor, Seabright Plaza, No. 9-23 Shell Street, North Point, Hong Kong Email: info@universaldistiny.com